Hikam Hulwanullah, Torik Abdul Aziz Wibowo
The absence of a direct constitutional complaint mechanism in Indonesia means that individuals still lack a legal means to contest violations of basic rights beyond the scope of judicial review. This study examines three main issues: the factors causing the absence of a constitutional complaint mechanism in Indonesia, a comparison of the objects and mechanisms of constitutional complaints in Germany, South Korea, and Spain, and the implementation of the Hybrid Multi-Level Constitutional Complaint in Indonesia. This study proposes an alternative model that aims to resolve constitutional rights disputes before this mechanism is officially regulated in the 1945 Constitution of the Republic of Indonesia. Copyright © 2026 by Constitutional Review.
Faculty of Law, Universitas Negeri Surabaya, Indonesia; Faculty of Law, Universitas Brawijaya, Indonesia
